Operational Policy 15 - Coupling Devices (Tow Dollies)

Two Operational Policies have published addressing the towing of vehicles and securement: From Operational Policy 15. 3.b (3) Is a vehicle being towed on a wheel lift behind a tow truck with the wheel of the towed vehicle on the ground required to be secured to the wheel lift? Answer: Yes, 49CFR 393.71(h)(5) requires the towed vehicle be secured to the wheel lift. In addition, 49CFR 393.71(h)(10) requires safety devices to be attached between the towing and towed vehicle. From Operational Policy 15 3.b. (3)(a) Is a vehicle being towed on a wheel lift behind a tow truck with the wheel of the towed vehicle on the ground required to be secured to the wheel lift? Answer: Yes, 49CFR 393.71(h)(5) requires the towed vehicle be secured to the wheel lift. In addition, 49CFR 393.71(h)(10) requires safety devices to be attached between the towing and towed vehicle. b.3.(b)is a vehicle being towed using wheel dollies, as pictured above, considered a driveaway/towaway operation? Answer: Yes, as long as it meets the definition of driveway/towaway in CFR 390.5T The two Operational Policy 15 notices above address the towing of disabled vehicles with a tow truck. The policy dated April of 2022 confirms the information/agreement that from discussions back in the 1980’s between the Federal Motor Carrier Safety Administration (FMCSA), Society of Automotive Engineers (SAE), Towing equipment manufacturers and towing industry representatives when wheel lifts were becoming popular. The policy dated Sept. of 2025 updates that information by now addressing the securement of the towed vehicle when using a portable tow dolly. This use of portable tow dolly was not addressed previously in the regulations although tow training programs and the industry standard and practice for a number of years has been to recommend securing the vehicle into the dolly as a significant safety issue.

This is somewhat similar to the issue with the wording and intent in 49CFR 393.128 with regard to car carriers which has been discussed for a number of years now attempting to clarify the wording of the regulation as to its intent and align it with industry standards and practices. Perhaps a look at other regulations relevant to the towing industry would also be helpful. The existing text and explanation for tow truck and towing equipment and securement is confusing to tow operators as well as commercial officers and then eventually the traffic courts.

Having something in print is good but it needs to be simpler and to the point so that it could be used as both a training or teaching tool as well as an enforcement tool. Simplifying and clarifying what is expected by the regulation would be a benefit for all.